EXHIBIT TO PLAINTIFFS' MOTION FOR LEAVE TO FILE SUPPLEMENT;
SUPPLEMENT TO OPPOSITION TO MOTION OF LINDA R.

TRIPP FOR A PROTECTIVE ORDER AND

OBJECTION TO SUBPOENA

Larry Klayman, Esq.

DC Bar No. 334581

Paul J. Orfanedes, Esq.

DC Bar No. 429716

Allan J. Favish, Esq.

JUDICIAL WATCH, INC.

501 School Street, S.W., Ste. 725

Washington, DC 20024

(202) 646-5172

Attorneys for Plaintiffs

AFFIDAVIT

The undersigned, who were present during a conference call with Mr. Anthony Zaccagnini
on September 1, 1998, hereby swear under penalty of law, that Mr. Zaccagnini stated a likely concern
of Ms. Tripp in being videotaped was that it would reduce her marketability to sell her story for
television appearances. Executed on September 3, 1998 in Washington, DC

__________________________

Larry Klayman, Esq.

________________________

Thomas J. Fitton, President

________________________

Paul J. Orfanedes, Esq.

________________________

Alan J. Favish, Esq.

CERTIFICATE OF SERVICE

I hereby certify that on September 8, 1998 a true and correct copy of the foregoing EXHIBIT
TO PLAINTIFFS' MOTION FOR LEAVE TO FILE SUPPLEMENT; SUPPLEMENT TO
OPPOSITION TO MOTION OF LINDA R. TRIPP FOR A PROTECTIVE ORDER AND
OBJECTION TO SUBPOENA was served by facsimile and U.S. mail, postage prepaid, on on the
following:

Attorneys for Defendants Federal Bureau of Investigation and Executive